Stanley v. State
112 So. 3d 718
Fla. Dist. Ct. App.2013Background
- Stanley was convicted by a jury of several lewd and lascivious crimes and kidnapping.
- The State charged kidnapping under Fla. Stat. § 787.01(l)(a)(2) and (l)(a)(3).
- On appeal, Stanley challenged the sufficiency of the kidnapping evidence; the court affirmed in part and reversed in part.
- The court held the kidnapping conviction was not supported by the Faison test for confinement to facilitate another crime.
- The court remanded to enter a conviction for false imprisonment and sentence accordingly.
- A concurring judge disputed two Faison factors based on the record, but agreed the kidnapping charge failed as to the evidence reviewed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the confinement justified kidnapping under Faison. | Stanley | State | No kidnapping; confinement insufficient under Faison |
| 是否适用Faison框架评估建议的绑架是否成立 | Stanley | State | Faison applies; confinement lacks independent significance |
| Whether the lesser included offense false imprisonment should be convicted | State | Stanley | Yes; remand for false imprisonment and sentencing |
Key Cases Cited
- Mobley v. State, 409 So.2d 1031 (Fla. 1982) (provides framework for kidnapping beyond mere confinement)
- Faison v. State, 426 So.2d 963 (Fla. 1983) (three-prong test for confinement to facilitate a crime)
- Buggs v. State, 219 Kan. 203, 547 P.2d 720 (1976) (informs Faison framework)
- Berry v. State, 668 So.2d 967 (Fla. 1996) (held confinement must not be merely incidental to the underlying offense)
- Ferguson v. State, 533 So.2d 763 (Fla. 1988) (requires significant independent effect of confinement)